M25 junction 28 improvements

Representations received regarding M25 junction 28 improvements

The list below includes all those who registered to put their case on M25 junction 28 improvements and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Jane Allan
"Please consider my issues/concerns below: Long term increased traffic, noise (day and night) and widespread congestion adjacent to my home- particularly with increased congestion travelling from the A12 on to the M25 northbound- suggest a free flow road is installed at M25j28 roundabout. Increased long term problems driving from my home and returning to my home due to increased traffic and congestion (including all local and major road links) plus restricted access and unacceptable delays to emergency services hence I would like to request that prior to commencement of the M25j28 roadworks changes are made along the A12 to allow residents of Woodstock Avenue to turn right without having to drive round the M25j28 roundabout. The majority of my journeys involve this route. I would like to request that this specific point is urgently highlighted to the Secretary of State (for consideration) dealing with approval of this scheme. Restricted access to poorly maintained public paths and public transport (buses) plus unsafe foot paths along the A12 and across M25j28 - limited barriers/ crossings and uneven surfaces for walking, cycling, wheelchairs and disabled vehicles. Increased flooding on M25j28 roundabout towards Brentwood (A1023). Increased pollution and flooding in my surrounding area- particularly from Maylands fields and the Grove Farm area on to the A12. Disturbances to wildlife in the vicinity of the roadworks. Devaluation of my home. I also have concerns regarding communication issues between all agencies involved including Highways England, TFL, Havering Council and Essex County Council - responsibilities for important issues which cross boundaries (as many do- for example flooding on the M25j28 roundabout towards Brentwood as soon as it rains) should be clearly defined and monitored for completion within a realistic time frame. I would like to request: - a co-ordinated approach is taken with local residents and to request that where possible information is shared in plain English - maybe a designated helpline/ email address? - scheduled/ ad hoc meetings (virtual if necessary) are held with local residents/ their representative groups as necessary throughout the planned roadworks? I request total transparency from all parties involved with this project. Thank you."
Local Authorities
Brentwood Borough Council
"Brentwood Borough Council is a host authority as the application red line includes a small area within the borough. Notwithstanding this Advice Note 2 (S18) encourages local authorities to register to take part in the process. On behalf of Brentwood my representations are likely to be limited to the effects the proposal may have on this local authority area rather than the broader issues of the proposal. In pre application discussions it was established that the issues that are likely to be relevant to Brentwood's comments may include the visual effect of the proposal, landscape, ecology, noise and air quality. We have had useful discussions in that process and therefore the extent to which I will need to comment further will be assessed later in the process."
Local Authorities
Essex County Council
"Essex County Council is a statutory consultee on the scheme and wishes to register to participate in the examination."
Other Statutory Consultees
Cadent Gas Limited
"RELEVANT REPRESENTATION Representation by Cadent Gas Limited (Cadent) to the M25 Junction 28 Improvement Development Consent Order Cadent is a licensed gas transporter under the Gas Act 1986, with a statutory responsibility to operate and maintain the gas distribution networks in North London, Central and North West England. Cadent’s primary duties are to operate, maintain and develop its networks in an economic, efficient and coordinated way. Cadent wishes to make a relevant representation to the M25 Junction 28 Improvement DCO in order to protect its position in light of infrastructure which is within or in close proximity to the proposed DCO boundary. Cadent’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the order limits including should be maintained at all times and access to inspect such apparatus must not be restricted. Cadent has a high pressure (major accident hazard) gas pipeline which are affected by works proposed and which may require diversions subject to the impact. Cadent has been liaising with the Promoter since early 2019 in respect of potential impacts to its apparatus and a detailed design review is underway which will be complete January 2020 however an adequate form of Protective Provisions has yet to be agreed for inclusion within the DCO. As a responsible statutory undertaker, Cadent’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. Cadent wishes to reserve the right to make further representations as part of the examination process but in the meantime will seek to engage with the promoter with a view to reaching a satisfactory agreement."
Members of the Public/Businesses
Anthony Arthur Manley
"My reservations concerning the proposed junction 28 Brook street improvements are as follows:- The road noise and air pollution are bad enough now, especially when the wind is coming from the east, which is a lot of the time, keeping us awake most nights and this will become significantly worse during and after the road alterations particularly if night time construction takes place using heavy machinery. The drainage on the A12 slip road and on Brook Street roundabout is bad with frequent flooding when the weather turns wet. I have reported on several occasions to TFL and Havering council that there is a sewage leakage just before the slip road near a gate, running across the footpath but this has not been resolved. I am sure that the message has not got through to the people at the top of the chain regarding the devastation caused by any roadworks or accidents/breakdowns on the A12 or M25 in this area. The backlash I have to suffer from having to wait sometimes hours to get out of my road, just to go to work or do the shopping or attend one of my many clinic appointments is already unacceptable. This has also been a problem with emergency services not being able to access/exit our road. I am sure that if a right turn was put in place, this would make it possible for all the residents in our road and also Kenilworth Avenue to avoid Brook street altogether, thus eliminating these problems. I moved to [Redacted] over 20 years ago with the main reason being able to look out over the fields. This is going to change when the new link road is constructed as it will be in full view from my bedroom window. The changes to this junction will have a negative effect on the value of my home. As a neighbourhood watch coordinator, I try to be proactive and requested a meeting with all parties involved (HE, Havering Council, TFL, Essex CC) with this project to highlight and reiterate our many concerns as a neighbourhood. This meeting took place at the Holiday Inn Brentwood on 20th March 2019 and minutes were kindly produced by [Redacted]. Our major concern throughout this whole consultation process is access to and from our road (plus Kenilworth Avenue) and being able to avoid the M25j28 roundabout. Please can this particular issue be raised at the highest level as this significantly impacts all our daily lives (residents of Woodstock and Kenilworth Avenue). I would like to be reassured that all issues highlighted by myself and all other residents involved have been heard by the right people involved in this project?"
Members of the Public/Businesses
Gillian Edwards
"I am concerned that the existing one way system from Woodstock Avenue forcing residents to have to travel around the J28 roundabout will become more difficult and more time consuming to manoeuvre. The noise and pollution levels will increase. Although I recognise the need for the junction to be altered the residents of Woodstock Avenue will continue to experience traffic delays and disruption to daily life. We desperately need a route to be installed to prevent the need for having to travel around the junction. I am particularly concerned about emergency and care services having limited access to our road during this time as we have many elderly residents who Moved to Woodstock Avenue prior to the M25 being built in the 1980s. We have problems with council services already and this will surely add to the difficulties."
Members of the Public/Businesses
Louise Bowyer
"I am very concerned as the traffic at the around about is already a nightmare daily for us. As you mat be aware Woodstock avenue have to use the round daily to get anywhere. I have to leave at 8am too get to school for 8.45 at Wigleybush Lane which is just the other side of the round about. Some days I do not make it on time. I would like for there to be a slip road on the A12 for us to possibly turn into Maylands way so that we do not have to go round the roundabout once works commence. This would mean that we could go the back way into Brentwood for school and shopping without getting stuck on the round about for hours. Kind Regards Louise"
Members of the Public/Businesses
Mr Groves on behalf of the Groves family
"As we the residents of (Redacted) are the last street before the M25/junction28 and have no access to a right turn at the end of our road, we would have to endure constant delays exiting and entering our road. Both day and night probably for 3 years once the project begins. As well as the constant noise of the works again both night and day. There is also a concern of the environmental impact this may cause both of the wildlife and the increase pollution as a result of the motorway being closer to our property. It is therefore my opinion that there has been no thought of the effect these works will have of the residents of (Redacted)."
Members of the Public/Businesses
Steven Monksfield
"I have concerns regarding the disruption to traffic when trying to get round the brentwood roundabout whilst the improvements are going on . As you will be aware the residents that live in our road have no option but to go round the Brentwood roundabout every time we leave our homes . I feel very strongly that we need a right hand turn from the a12 maybe near the junction with Maylands way to give us an option of avoiding the roundabout . Much similar to the one we currently have at the bottom of kenilworth ave . Without this in place I feel it will be virtually impossible for us to get our children to school or ourselves to work on time due to the extra time it will take to go round the roundabout. Regards Steven monksfield"
Members of the Public/Businesses
Jason Ellis
"M25, J28 planned works [Redacted] I write with reference to the above and following receipt of a letter about the works on the 21st July 2020. I have reviewed the plans and whilst I understand the need to make the amendments to aid flow of traffic etc the duration of the works and increased traffic noise is going to affect my property. What is the intention and compensation that is intended for property owners like myself who are going to suffer for the duration of the works and future increase traffic and noise levels which will ultimately affect the value and desirability of the property. Await to hear proposals in both regards."
Members of the Public/Businesses
A Harding
"I wish to raise my concerns for the planned M25 road improvements: I live in [Redacted] and would like to know what plans will be put in place for us to leave our road as we can only turn left and go around the M25 roundabout. I am concerned should we need any emergency services they will not be able to get to us. The years of disruption that these works are going to cause for the surrounding roads is so worrying. Having witnessed and sat in the traffic jam caused just by reducing the A12 to one lane for pavement improvements the beginning of August is worrying enough ! The noise and levels of the work is also very concerning and will this be going on all night ? i am concerned too that the link road is going to be closer to our homes, how again is this going to impact us, noise levels from traffic , air pollution and our property values. It is also concerning that the works have been given a timescale but like all 'improvements' these always over run and timescales are never met !"
Local Authorities
Chelmsford City Council
"Thank you for consulting Chelmsford City Council on the above scheme. The scheme is supported by Chelmsford City Council as it will: • reduce congestion • improve safety • support development and economic growth. Chelmsford City Council agrees with all the proposed infrastructure measures proposed to achieve the above improvements. Chelmsford City Council would not wish to make any comments on matters such as heritage, biodiversity, geology, drainage, utilities and visual impact since these are more relevant for the host authority. Chelmsford City Council wishes to remain involved in future consultations."
Local Authorities
Essex County Council
"Essex County Council generally supports the scheme however we remain concerned on the affect the scheme will have on traffic trying to access the junction from Brook Street. Currently there is significant traffic congestion that will worsen with the scheme. The congestion that has been indicated by Highways England could be of a scale that will have adverse effects on Brentwood's emerging local plan and mean that some potential sites in the area of Warley will be unable to come forward. The proposal will worsen traffic conditions for all using Brook Street and they are no current plans for any mitigation."
Other Statutory Consultees
Public Health England
"Thank you for your consultation regarding the above development. Public Health England (PHE) welcomes the opportunity to comment on your proposals at this stage of the project and can confirm that:- With respect to Registration of Interest documentation, we are reassured that earlier comments raised by us on 28th January 2019 and 21st November 2019 have been addressed. In addition, we acknowledge that the Environmental Statement (ES) has not identified any issues which could significantly affect public health. We are satisfied with the methodology used to undertake the environmental assessment. We note that the main ground investigation and associated risk assessment have not been provided. It is assumed that these will be agreed with the relevant local authorities in consultation with the Environment Agency, as the relevant regulatory authorities with regards to land contamination. PHE notes that the Environmental Statement Chapter 13: People and Communities was developed using the methodology provided by DMRB Volume 11 Section 3. However, this methodology was superseded by DMRB LA112: Population and Human Health, in January 2020. It is therefore our expectation that the most recent Highways England methodology should be used to assess and report the effect of this development on population and human health. On the basis of the documentation as reviewed we have no additional comments to make at this stage and can confirm that we have chosen NOT to register an interest with the Planning Inspectorate on this occasion. Please do not hesitate to contact us if you have any questions or concerns."
Members of the Public/Businesses
Jessie Mcdonnell
"I am extremely concerned about the noice and pollution these new road will cause. Also concerned about the amount of traffic. I am opposing this new road scheme"
Members of the Public/Businesses
response has attachments
Luddington Golf Limited
"Luddington Golf Limited (LGL) are the long Leaseholders and operators of Maylands Golf Course (MGC) which will be affected by this Scheme/ Application in the following ways : 1)Maylands will lose use of the clubs Practice Range area for the duration of the construction works. The practice Range is an integral element of the Golf business at Maylands and by loosing these facilities it will detrimentally affect both members and visitors . This will negatively impact on the business through general loss of income, the teachers will not be able to teach and therefore lose their income, and membership and visitor play will diminish due to the inability of the Club to offer such facilities which will negatively impact on revenues for the business. Highways England have offered no alternative or replacement for these practice facilities. 2)The proposed road will have a significant detrimental impact on the 1st and 2nd holes at Maylands both in terms of : length , playability, quality of the landscape, visual and noise pollution and generally the leisure experience for the users whether they be member or visitor. This in turn will have a negative impact on the business and therefore the future sustainability of the course and the business. During the consultation process with Highways England (HE) over the scheme, LGL and MGC were asked to provide an Impact Assessment Report on the effect of the scheme on the golf course. Weller Designs Limited (highly regarded Golf Course Architects) were instructed to provide the report and within it provide alternatives for alterations to the course to keep it intact as an 18 hole Golf Course and Practice Range. This report was funded by HE and within it Weller Designs provided alternatives that would mitigate in particular (and as a minimum) the effect on the 2nd Hole and what might be acceptable to the operators of MGC as an alternative. Following submission of the report HE then asked Weller Designs to present a 'do minimum' scheme of alterations which they did. This was still not accepted by HE who then employed another golf course architect to produce a further ‘do minimum” alternative which now forms part of this planning application. This alternative was assessed by Weller Designs who concluded that the scheme would be undesirable both in design and operational terms on the following basis: i) Health and Safety. After playing the hole players have to take a potentially dangerous walk back down the play line to the next hole. ii) It is disruptive operationally and will cause long delays to the golf course ‘round time’. iii) It will deter members and visitors and therefore have a negative impact on the business and its sustainability. iv)Therefore it will have a negative impact on the sustainability of this historical and established golf course designed by the renowned architect Harry Colt and arguably one of the best courses in Essex. V) It is ecologically disadvantageous compared to the Weller Designs Scheme LGl have provided their findings to HE and have concluded that the suggested alterations to the golf course in this scheme would be unacceptable going forward and have a negative impact on the business and future sustainability of the course and business. LGL also asked Weller Designs to further modify their proposed scheme in terms of total 'Land take' and 'costs of construction', which they have done and have presented to HE. We object to the application because the current scheme does not give reasonable mitigation of the negative effects of the new road on the business, the club and the land at Maylands GC. Reasonable alternatives have been presented by Ourselves and our professional advisors, Weller Designs, through their impact assessment and subsequent alternative scheme which we believe have not been considered properly or in the correct context."
Other Statutory Consultees
response has attachments
National Grid Electricity Transmission PLC and National Grid Gas
"Submission withdrawn – see attached Representation by National Grid Electricity Transmission Plc (“National Grid”) to the Proposed M25 Junction 28 Development Consent Order (“the Project”) National Grid wishes to make a relevant representation to the Project in order to protect its position in relation to infrastructure and land which is within or in close proximity to the proposed Order Limits. National Grid’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the Order limits should be maintained at all times and access to inspect and maintain such apparatus must not be restricted. The documentation and plans submitted for the above proposed scheme have been reviewed in relation to impacts on National Grid’s existing and apparatus and land interests located within this area, and National Grid will require protective provisions to be included within the DCO to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. National Grid Electricity Transmission has a high voltage electricity overhead transmission line within and in close proximity to the Order Limits. The overhead line forms an essential part of the electricity transmission network in England and Wales as follows: • ZB (275kV) overhead line route -Elstree to Warley. National Grid Gas has a high pressure gas transmission pipeline located within and in close proximity to the proposed order limits. The transmission pipeline forms an essential part of the gas transmission network in England, Wales and Scotland: • Feeder Main 18 (Stapleford Tawney to Horndon ‘A’). As a responsible statutory undertaker, National Grid’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. National Grid reserves the right to make further representations as part of the examination process but in the meantime is negotiating with the promoter with a view to reaching a satisfactory agreement."
Members of the Public/Businesses
BNP Paribas Real Estate on behalf of Royal Mail Group
"BNPPRE act on behalf of Royal Mail and whilst our clients do not have an in principle objection to the proposed scheme we are seeking to secure mitigations to protect our operations within the location of the project. Under section 35 of the Postal Services Act 2011 (the “Act”), Royal Mail has been designated by Ofcom as a provider of the Universal Postal Service. Royal Mail is the only such provider in the United Kingdom. The Act provides that Ofcom’s primary regulatory duty is to secure the provision of the Universal Postal Service. Ofcom discharges this duty by imposing regulatory conditions on Royal Mail, requiring it to provide the Universal Postal Service. The Act includes a set of minimum standards for Universal Service Providers, which Ofcom must secure. The conditions imposed by Ofcom reflect those standards. Royal Mail is under some of the highest specification performance obligations for quality of service in Europe. Its performance of the Universal Service Provider obligations is in the public interest and should not be affected detrimentally by any statutorily authorised project. Royal Mail’s postal sorting and delivery operations rely heavily on road communications. Royal Mail’s ability to provide efficient mail collection, sorting and delivery to the public is sensitive to changes in the capacity of the highway network. Royal Mail is a major road user nationally. Disruption to the highway network and traffic delays can have direct consequences on Royal Mail’s operations, its ability to meet the Universal Service Obligation and comply with the regulatory regime for postal services thereby presenting a significant risk to Royal Mail’s business. There are eight operational facilities within 8 miles of this proposal, Brentwood VP/DO, Harold hill DO, Hornchurch DO, Romford MC, Upminster DO and Billericay DO. The location, nature and scale of the proposed improvements could present risk of construction phase impact / delays to Royal Mail’s road based operations on the surrounding road network. Every day, in exercising its statutory duties Royal Mail vehicles use all the main roads that may potentially be affected by additional traffic arising from the construction of the proposed junction improvements. Any periods of road disruption / closure, night or day, have the potential to impact operations. Royal Mail does not wish to stop or delay the improvements from coming forward for development. However, Royal Mail does wish to ensure the protection of its future ability to provide an efficient mail sorting and delivering service. In order to do this, Royal Mail requests that: 1. the DCO includes specific requirements that during the construction phase Royal Mail is consulted by Highways England or its contractors at least one month in advance on any proposed road closures / diversions / alternative access arrangements, hours of working, and the content of the final CTMP, and 2. The final CTMP includes a mechanism to inform major road users (including Royal Mail) about works affecting the local highways network (with particular regard to Royal Mail’s distribution facilities near the DCO application boundary as identified above). Royal Mail reserves its position to object to the DCO application if the above requests are not adequately addressed. Contacts for Royal Mail: Denise Stephenson ([email protected]) of Royal Mail’s Legal Services Team Alice Stephens ([email protected] of BNP Paribas Real Estate."
Members of the Public/Businesses
response has attachments
Eastern Power Networks plc
"Submission Withdrawn by Email dated 14th May 2021 (AS-042) I am writing on behalf of Eastern Power Networks plc (EPN). EPN owns and operates Electric Lines and/or Electrical Plant (as those terms are defined in Section 64(1) of the Electricity Act 1989) in, on, over or under the land to be acquired and/or temporarily used under the above Order. These rights and apparatus have been acquired and are used for the purposes of its statutory undertaking. EPN objects to the making and confirmation of the Order unless at the cost of the acquiring authority there are first provided to it on no less favourable tenure suitable alternative sites and suitable alternative rights in, on, over or under land in substitution to those to be acquired and/or temporarily used under the above Order and in, on over or under which there are first installed and commissioned Electric Lines and Electrical Plant in substitution for those in the land to be acquired and/or temporarily used under the above Order, before that land is acquired and/or temporarily used so that my client can carry out its statutory functions and contractual obligations no less efficiently than previously. Please treat this letter as an objection by EPN to the relocation/extinguishment of rights and apparatus mentioned above because their relocation will be detrimental to the carrying on of its undertaking. No alternative land, rights and apparatus for those proposed to be acquired under the above Order are in place. EPN reserves the right to amend or supplement its objections in the light of any information that later becomes available. The above objection(s) will be deemed to be withdrawn upon signature of an appropriate deed of Undertaking by an authorised signatory of the Acquiring Authority."
Other Statutory Consultees
response has attachments
Addleshaw Goddard LLP on behalf of Network Rail Infrastructure Limited
"Submission Withdrawn by Email dated 7th July 2021 (REP10-024) APPLICATION BY HIGHWAYS ENGLAND FOR AN ORDER GRANTING DEVELOPMENT CONSENT FOR THE M25 JUNCTION 28 IMPROVEMENT SCHEME PLANNING INSPECTORATE REFERENCE: TR010029 SECTION 56 PLANNING ACT 2008: RELEVANT REPRESENTATION OF NETWORK RAIL INFRASTRUCTURE LIMITED This is the section 56 representation of Network Rail Infrastructure Limited (Network Rail) provided in respect of Highways England's (Promoter) application for a development consent order (Order) for the M25 Junction 28 Improvement Scheme (Scheme). Network Rail is a statutory undertaker and owns, operates and maintains the majority of the rail infrastructure of Great Britain, including the Shenfield to Liverpool Street line which crosses the Promoter's motorway to the North East of Nag's Head Lane, Brentwood, Essex, immediately south of Junction 28 of the M25 (Railway). The Order sought by the Promoter includes consent and powers to upgrade its motorway at Junction 28. The Promoter seeks authority and powers in the draft Order for works to be carried out to its existing motorway directly beneath an operational rail bridge belonging to Network Rail (Bridge) and intends to acquire all interests and rights in the plot beneath the Bridge to the extent that the land does not belong to Network Rail. Network Rail wishes to ensure that the Scheme will not have a detrimental impact on the operation of the Railway and the Bridge and that the safety of the Railway and Bridge is maintained during the construction, operation and ongoing maintenance requirements of the Scheme. As the Promoter proposes to carry out works directly beneath Network Rail's bridge and in close proximity to the Railway, Network Rail wishes to object to the making of the Order on the ground that the proposed works might interfere with the safe and efficient operation of the Railway. In order for Network Rail to be in a position to withdraw its objection Network Rail will require adequate protective provisions and/or requirements to be included within the Order and an agreement with the Promoter to ensure that the works for the Scheme are carried out in regulated manner to prevent adverse impacts to the Railway and which regulate the following: a) the protection of the Bridge and Railway from adverse impacts during construction of the Scheme; b) the liability of the Promoter for any necessary repairs and upgrades to the Bridge as a result of its use by construction and operational traffic associated with the Scheme, including terms which protect Network Rail's statutory undertaking; and c) a safe system of work for large vehicles working beneath the Railway. Network Rail is continuing to review the Promoter's plans, draft Order and application documents, and will continue to work constructively with the Promoter to clarify any issues raised. The Examining Authority and the Secretary of State will need to be satisfied that railway safety and operations will not be compromised by the making of the Order. Network Rail requests that the Examining Authority treats Network Rail as an Interested Party for the purposes of the Examination, and reserves the right to produce additional and further grounds of concern when further details of the Scheme and its effects on Network Rail's assets are available."
Local Authorities
Thurrock Council
"On the basis of the application accepted for examination on 24th June 2020, Thurrock Council raises no objections to the proposed development."
Other Statutory Consultees
Environment Agency
"Dear Sir/Madam Application by Highways England for an Order granting Development Consent for the proposed M25 Junction 28 Improvement Scheme Please find enclosed our relevant representation for the M25 junction 28 improvement scheme. The Environment Agency has a responsibility for protecting and improving the Environment as well as contributing to sustainable development. Our work helps to support a greener economy through protecting and improving the natural environment for beneficial uses, working with business to reduce waste and save money, and helping to ensure that the UK economy is ready to cope with climate change. We have three main roles: We are an environmental regulator – we take a risk-based approach and target our effort to maintain and improve Environmental standards and to minimize unnecessary burdens on business. We issue a range of permits and consents. We are an environmental operator – we are a national organization that operates locally. We work with people and communities across England to protect and improve the environment in an integrated way. We provide a vital incident response capability. We are an environmental advisor – we compile and assess the best available evidence and use this to report on the state of the environment. We use our own monitoring information and that of others to inform this activity. We provide technical information and advice to national and local governments to support their roles in policy and decision-making. One of our specific functions is as a Flood Risk Management Authority. We have a general supervisory duty relating to specific flood risk management matters in respect of flood risk arising from Main Rivers or the sea. Highways England (the applicant) approached us in August 2017 to discuss their initial plans for the project and the potential environmental issues that they would need to address. Since this early contact we have had positive, consistent engagement with representatives of the applicant particularly in relation to matters concerning impacts on main rivers, water quality and flood risk. In January 2019 we provided a formal response to the Applicant’s Section 42 (Planning Act 2008) consultation. Following this, in December 2019 we provided a response to the Applicant’s Supplementary consultation on changes to the scheme design. Our relevant representation outlines where there is sufficient information for some matters (hence areas of agreement) and where we have identified issues that remain outstanding in our review of the application documents. These comments are aligned with our Statement of Common Ground with the applicant (reference: TR010029/APP/8.1). We will continue to engage with representatives of the applicant on these matters in the hope of resolving any issues not yet agreed. We can provide an update on the progress of our discussions in due course. Please do not hesitate to contact us if you require any further information. We look forward to continuing to work with the applicant to resolve any outstanding matters to ensure the best environmental outcome for this project. Yours faithfully Keira Murphy Planning Specialist Sustainable Places, Hertfordshire & North London Relevant Representations On behalf of the Environment Agency Areas of agreement and outstanding issues 1.0 Draft Order 1.1 Although the published protective provisions for the Environment Agency (Schedule 9, Part 3) within the draft Order (reference: TR010029/APP/3.1) are based on our standard protective provisions (dated April 2019), there are some deviations and changes to the wording. We have previously advised the applicant that they should use our standard protective provisions in any Order, and that we would be unlikely to be able to agree to disapplication of any legislation unless this form of protective provisions appears in the DCO. 1.2 We are considering the form of protective provisions put forward by the applicant and will engage with the representatives of the applicant on these matters shortly. 2.0 Waste deposits 2.1 Waste is an outstanding issue. The baseline conditions within Chapter 12 Materials and Waste (reference: TR010029/APP/6.1) identify the historic landfill (former Brook Street) and unpermitted recently deposited waste. The Work Plans TR010029/APP/2.3 also demonstrate that part of the scheme construction will occur in both these areas. We note that investigations and potential actions regarding the unpermitted recently deposited waste are still ongoing. 2.2 We are concerned that the only mechanism referenced (paragraphs 12.8.8 and 12.12.4) for dealing with these wastes at the application site is a Materials Management Plan (MMP). The MMP is also referenced within the Register of Environmental Actions and Commitments (REAC, document reference: TR010029 7.3) as requirements MW1.1 and MW2.1. MMPs are used as part of a CL:AIRE Definition of Waste Code of Practice (DoWCoP) to permit the re-use of both natural soils and made-ground without the need to apply for an Environmental Permit. Soil reuse under the CL:AIRE DoWCoP arrangement is possible for sites where naturally occurring uncontaminated soils are found. However this will not be possible for materials deposited as waste either within the historical landfill or the unpermitted recently deposited waste. Both these areas are considered controlled waste and the recovery of them will require an Environmental Permit. DoWCoP specifically excludes landfill and waste from its scope therefore this framework cannot be used for a large part of the scheme’s development. We would also need to discuss in due course the status of the existing Environmental Permit for the permitted section of the site. The existing Environmental Permit would need to be surrendered following the removal of waste and decommissioning of the permitted part of the site. 2.3 Although there are some brief references to the Environmental Permitting Regulations with Table 1.2 of Chapter 12, and also Appendix A of the Consents and Agreements Positions Statement (TR010029/APP/2.13), this is not explicit enough. The advice we provided at the Section 42 Planning Act 2008 consultation was clear, that Chapter 12 Materials and Waste needed to reference the need for an Environmental Permit to complete these works and allow the treatment, or redeposit of suitable waste to achieve the desired landform. This was also an issue we raised in our response to the scoping consultation in December 2017. This matter can be satisfactorily resolved if a commitment to obtain an Environmental Permit from us in respect of the areas of controlled wastes on site (the historic landfill (former Brook Street) and unpermitted recently deposited waste) is included within Tables 1.1 and 1.2 of the REAC. We also ask that the Statement of Common Ground is updated to reflect this. 2.4 We will engage with the representatives of the applicant on these matters shortly. We can provide more detailed written representations at a later date should any matters be ongoing. 3.0 Flood risk 3.1 The application site is partially within Flood Zone 2 and 3 which represent zones of medium and high annual probability of fluvial flooding from the River Ingrebourne and the Weald Brook. 3.2 The Flood Risk Assessment (document reference: TR010029/APP/6.6) has assessed the impact of the scheme works on the flood risk. The works assessed include the proposed M25 loop road, the M25 offslip and A12 onslip, the River Ingrebourne and Weald Brook culvert extensions and the river realignments. Floodplain compensation areas have been provided to mitigate for any displacement of flood storage by the scheme, to ensure there is no loss of floodplain storage during any design event including 35% for climate change. We agree that there would be no increase in fluvial flood risk as a result of the works, notwithstanding any requirements to obtain our approval for the works close to watercourses as required. 3.3 Hydraulic modelling was undertaken to understand the baseline flood risk at the site and assess suitable mitigation. We believe the modelling is sufficient to underpin the assessment of flood risk and design of mitigation measures. We have no concerns with the proposed phasing arrangements for delivery of floodplain compensation areas to ensure that at no point during the scheme construction there will be a loss of flood storage on site. 3.4 We will continue to engage with representatives of the applicant on the river crossing bridge designs. These should be designed with a 600mm freeboard above the 1 in 100 year plus climate change flood level but where this cannot be achieved demonstrate how they will withstand the impact of floating debris during a flood event. As agreed within our Statement of Common Ground (document reference: TR010029/APP/8.1) these designs will be submitted for our approval at protective provisions stage. Therefore we consider that flood risk is an area of agreement. 3.5 As a minor point, the REAC (document reference: TR010029 7.3) references that we are proposed to review information related to surface water flood risk or drainage (e.g. RD1.9 and RD1.10 under Table 1.2 Actions before the start of construction). Although we have an interest in pollution prevention and water quality, surface water flood risks and the design of surface water runoff are not within our remit, so other responsible agencies such as the relevant lead local flood authority will need to agree to review these details. 4.0 Water Framework Directive Mitigation works 4.1 During the pre-application phase our discussions with the applicant have focused largely on our concerns regarding the impact of the proposed scheme on the River Ingrebourne and Weald Brook. Both are main rivers and therefore overseen by the Environment Agency as a regulator should any works be proposed either in-channel or within close proximity. Our discussions focussed broadly on the impacts on the rivers from the scheme’s bridges (Grove Bridge, Duck Wood Bridge and Maylands Bridge) and the Grove culvert extension on the River Ingrebourne. We stated early on in the discussions that we expected a scheme of this size to provide environmental improvements to the main watercourses affected by the scheme, in addition to any mitigation / compensation measures required. 4.2 As the competent authority on Water Framework Directive (WFD) 2000/60/EC we investigate the current condition of rivers and publish the data. The River Ingrebourne is currently classified as achieving ‘moderate’ status under the Water Framework Directive (WFD). The Weald Brook is a main tributary of the River Ingrebourne. Although the Weald Brook is not classified separately under the WFD, its condition contributes to the overall WFD status of the Ingrebourne river catchment. Our Thames River Basin Management Plan (2015) sets out the objectives to help all waterbodies achieve good status, and we aim to work in partnership with others to improve waterbodies. We would not be able to accept proposals likely to cause further deterioration to a WFD designated river or prevent it from attaining good status in the future. The Water Framework Directive Assessment (reference: TR010029/APP/6.7) submitted with this application has provided a sufficiently detailed assessment of the impacts and proposed mitigation. 4.3 We agree that with the appropriate mitigation measures in place which consist of the embedded and additional mitigation both within and outside the DCO boundary, the scheme will be WFD compliant. We have been able to reach a broad agreement on an acceptable package of mitigation measures for impacts to the River Ingrebourne and Weald Brook within the DCO boundary. We support the additional enhancements such as floodplain lowering, unlined ephemeral drainage ditches and maintenance of riparian trees which will add enhanced habitat value. 4.4 As we have noted through our pre-application engagement on this scheme, the additional mitigation measures also include mitigation works outside of the DCO boundary. This is because (and we agree) that with all the mitigation measures within the DCO boundary this still results in a deficit in riverine habitat (Appendix E of WFD Assessment). With support provided by the applicant’s consultants we have identified potential options for off-site mitigation works on the WFD Ingrebourne waterbody. This is recognised within the WFD Assessment in paragraph 5.3.1 as W13 (Mitigation works, outside of the DCO boundary, delivered by the EA as part of their programme of works within the Ingrebourne WFD waterbody). Further work will be carried out to investigate the feasibility prior to implementation of one or a combination of mitigation options we have identified. We are in receipt of Heads of Terms for the legal agreement in relation to this and will continue to liaise with representatives of the applicant. 4.5 We are broadly satisfied with the environmental mitigation commitments set out within Parts 1 and 2 of the REAC for Biodiversity and Road Drainage and Water Environment, and look forward to commenting further at detailed design stages. 4.6 Therefore we consider that WFD mitigation and compliance is in principle an area of agreement and provided an agreement on terms acceptable to the Environment Agency can be concluded this issue should be resolved. 5.0 Groundwater and land contamination 5.1 The applicant has undertaken a preliminary ground investigation for the site (Appendix 10.1 Preliminary Geo environmental Assessment Report TR010029/APP/6.3). The baseline conditions have been adequately characterised for the DCO application and we believe the scheme could be implemented without presenting an unacceptable risk to controlled waters. GS1.1 of Table 1.2 of the REAC (document reference: TR010029 7.3) has included the commitment to a Ground Investigation Report and where contamination risks are identified and mitigation required, a Site Specific Remediation Strategy. Given that piled foundations will be required for the proposed bridge crossings we also support the inclusion of a Piling Risk Assessment in GS1.1 and GS1.4 of the REAC. 5.2 We are therefore satisfied that any outstanding issues can be addressed through the appropriate Requirements and the environmental commitments listed within the REAC. We will continue engage with the representatives of the applicant on these matters if necessary."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Gardens of Peace Muslim Cemetery
"Dear Sir / Madam Gardens of Peace Muslim Cemetery - Plots 1/8 - Representation against Highways England’s M25 Junction 28 Improvement Scheme Savills (UK) Ltd has been instructed by the Trustees of Gardens of Peace Muslim Cemetery to act on their behalf in relation to the M25 Junction 28 Improvement Scheme (“the Scheme”). As per Highways England (HE) letter dated 14th May 2020 with Development Consent Order (DCO) plans enclosed, Gardens of Peace owns Plot 1/8. Please note, whilst Gardens of Peace appear to be the registered owner Plot 1/9, this is an error at Land Registry and accordingly Gardens of Peace are in the process of having a boundary survey undertaken with the revised plan registered at the Land Registry by early November. This will remove what HE identify as Plot 1/9 from their ownership. Plot 1/8 is subject to temporary possession with permanent rights. In response to HE letter addressed to Gardens of Peace, dated 21st July 2020, we are instructed to submit the following representation against HE’s Scheme. Gardens of Peace is a charity, and thus non-profit making, providing burials for the Muslim community in London. Gardens of Peace rely solely on Lillah donations and burial and funeral fees to maintain the cemeteries, pay wages and to build a fund for future maintenance and development of cemetery land. Given the nature of cemeteries, Gardens of Peace are required to plan well in advance for future expansion. Accordingly, Gardens of Peace acquired 30 acres of land (known as “Maylands”) in 2007 to ensure they had a “land bank” for a new cemetery to serve the Muslim community once the existing cemetery neared capacity. Plots 1/8 forms part of Maylands. In recent years, it was evident the new cemetery was required and accordingly, Gardens of Peace applied for planning permission in 2014 which was declined. Planning was subsequently approved on Appeal on 23/1/2017. However, whilst Gardens of Peace were already under pressure to commence development of the new cemetery, Covid-19 exacerbated this pressure with an increase in mortality rates. Gardens of Peace are now under significant time pressure to open their new Cemetery to allow for adult burials. Maylands, including the area subject to Plot 1/8, has always been designated a greenfield site and therefore, the overall design and look of the proposed cemetery had to overcome a number of stringent conditions to be approved. Gardens of Peace have already expended a considerable sum in professional fees to draw up the overall design for the optimum use of the site. The extensive preliminary ground works (costing in excess of £500,000) commenced in 2017, which included clearing the site, preserving the tress in woodland belt, work clearing soil of roots, harrowing, installing site services – ducts for water, electricity, borehole water, road works, foul connections, site drainage, fencing, perimeter screen planting and a boundary wall. In order to develop into a cemetery (which is due to commence in the first half of 2021), planning approval allows for the construction of a car park for cars and coaches, constructing an access off the A12 into the site with roads leading to the car park and the main office building and chapel facilities for mourners, extensive landscaping to make the cemetery a sympathetic area whilst providing up to 10,000 burials and constructing a building to act as general workshop / store. An opening date of February 2022 has always been targeted to allow a smooth transition from their current cemetery to Maylands. However, if the Scheme is progressed as proposed, meeting the opening date will not be possible for the following reasons: - The Scheme will cause delays and interruptions to Gardens of Peace’s contractor’s work schedule - Gardens of Peace will have to redesign their scheme to allow development of the cemetery whilst the junction improvement works are being undertaken - Even once the Scheme is completed, Gardens of Peace will not be able to open the cemetery as the subject area will require developing to allow the cemetery to be opened for burials and mourners. Having a part completed cemetery will not be acceptable to Gardens of Peace, given the sensitive use of the site. - We note on the HE website that the start date for the Scheme is listed as 2021-2022 and therefore will not be completed in advance of February 2022 to allow Gardens of Peace to progress their development. Accordingly, if the Scheme is progressed as proposed the opening of the cemetery will be entirely in the hands of HE contractors. In addition to the above, we also take this opportunity to raise the following concerns about the Scheme based on the information provided to date: i. Insufficient Information Provided – Whilst a conference call has been held with Gardens of Peace, their development advisors, Savills, Highways England and Atkins Global, further information could be provided for Gardens of Peace to better understand the effects of the Scheme on their property. A site meeting was provisionally arranged ahead of the representation deadline, but later cancelled as HE were not in a position to give any further clarity on the Scheme. We therefore currently have insufficient information to enable full understanding of the effects of the Scheme on Garden of Peace’s land and thus are not able to fully respond to the Scheme proposals. ii. Future Land Use Restrictions – We have requested on more than one occasion the proposed wording of the easement for the gas main. We are yet to have sight of this and are therefore unclear as to any future land use restrictions which may adversely impact on the number of burials available on the land. This is important to Gardens of Peace as the land was acquired for the purpose of a cemetery and if a large area is to be sterilised due to the presence of the gas main, the proposed cemetery will have to be redesigned. Furthermore, it will reduce the expected income generated by the sale of burials which could have a permanent impact on the reinvestment into the cemetery. iii. Area subject to Temporary Possession – The land subject to the DCO is excessive and can be redesigned to have a lesser impact on Gardens of Peace’s land, or, be moved entirely off Gardens of Peace’s land to minimise the disruptions caused by the Scheme’s and allow for the proper running of their intended use. iv. Development of the Site – During the construction period of the Scheme, the main access into the cemetery, the car parking area to be used by all mourners and a substantial number of burial sites, approximately 250, will be significantly affected. v. Gas Main Design – Cadent Gas have recently undertaken a walk over survey and it has been confirmed by Highways England that any detailed designs on the gas main will not be available until next year. This therefore causes Gardens of Peace uncertainty in terms of their current development plan and schedule and consequently may cause additional delays in commencing their development until Cadent have confirmed the final design of the gas main. vi. Effect of Construction – Gardens of Peace are also concerned about the effect of congestion caused by the junction improvement works on the running of the cemetery during the Scheme works. With all the above in mind, it is evident that if the Scheme is not amended as currently proposed, it will have a significant and long lasting detrimental effect on the cemetery at a time where there is already significant pressure to provide burial space. We reserve the right to amend, extend or withdraw this representation in due course. Please confirm receipt of this representation. Yours faithfully Gwyn Gwyn Church Savills (UK) Ltd"
Members of the Public/Businesses
Matthew Bodley Consulting Limited on behalf of Glebelands Estates Limited
"I act on behalf of Glebeland Estates Limited (“GEL”) which owns land in Romford which is affected by the M25 Junction 28 Improvements Development Consent Order being promoted by Highways England (“HE”). GEL owns approximately 300 acres of land to the west of junction 28 which is accessed via the A12 Colchester Road. The land includes the Maylands Golf and Country Club and surrounding land. A significant area of GEL’s land has been included in the Development Consent Order application. Approximately 195,000 m² (48 acres) has been identified as pink land for acquisition and a further 80,000 m² (20 acres) has been identified as green land for temporary possession. The Golf Club is leased to Luddington Golf Ltd (“LDL”) by way of a long lease. LDL operates the Golf Club. HE’s proposed land take includes land within the lease and will therefore have an effect on the landlord and tenant contractual relationship between GEL and LDL. Accordingly, I am in contact with LDL and have liaised with them regarding the potential impact on the Golf Course. The land which HE is seeking to acquire includes the second hole, the practice area as well as other parts of the Golf Course. A standard golf course requires 18 holes and the loss of any of the holes would be unacceptable. The Golf Club will be unable to operate if one of the holes is compulsorily acquired. I am aware of the contact that has taken place between HE and LDL regarding proposals to reconfigure parts of the Golf Course to accommodate HE’s proposed land acquisition. I am aware that LDL instructed Weller Design Ltd, a specialist Golf Course architect to undertake an impact assessment and to review the alternative design proposals put forward by HE. I have been provided with a summary of the outcome of Weller’s findings which conclude the HE’s proposals are unacceptable in health and safety, operational, playability, social, environmental, ecological and economic terms. In addition, to the potential loss of the second hole, the proposals will impact adversely upon the visual and noise amenity of the first hole and lead to the loss of the practice area. In summary, it will make the Golf Course less playable and less attractive to members and visitors which will weaken the standing of the course resulting in its deterioration which will have a severe adverse impact on the Golf Club and its members and guests. The worst case scenario would be that membership and revenues decline which could lead to a deterioration of the quality of the club or potentially threaten its future existence and result in closure. The Golf Club has existed in this location since 1936 having been designed by Harry Colt, a renowned twentieth century golf course architect. It is an historic and important community facility. It provides both physical exercise and mental health benefits to its members and their guests, many of whom are retired and elderly. The primary function of the club is the playing of golf but in addition the club hosts dinners and events which provides members and guests with the opportunity to meet and socialise with each other. The club also provides economic benefits in the form of employment to the ground staff, teachers, professionals and catering staff. HE’s proposals are likely to have a detrimental impact on the club which would in turn have a detrimental impact on the social and environmental well-being of its members, guests and employees which predominantly come from the local community. It will also have a detrimental impact on the economic well-being of the employees. I understand that LGL, and its architect Weller, has put forward alternative less intrusive proposals which would mitigate the adverse impacts of HE’s scheme but that these have been rejected by HE. In addition to the Golf Course, other land owned by GEL has been included for acquisition. My client intends to bring forward redevelopment proposals on its other land which are likely to be adversely affected by the proposed land acquisition. The full extent of this impact is not currently clear and we are in the process of reviewing this. GEL objects to the compulsory acquisition of its land due to the adverse impact it will have on the Golf Club and its other landholdings. Aside from its general objection to the acquisition of its land, GEL is of the opinion that the extent of land which has been identified for permanent acquisition is excessive and goes significantly beyond the extent of the permanent works. In particular, it is not apparent why there is a need for HE to permanently own significant parts of plots 1/10, 1/12, 1/13, 3/20 and 3/22. It appears that HE could achieve its objectives in an alternative less intrusive manner by reducing the extent of the landtake. This could be achieved by taking less land or alternatively it may be more appropriate to reduce the extent of the permanent landtake and instead take some of this land on a temporary basis and return it to my client on completion of the works, or a combination of the two. Furthermore, GEL has road safety concerns regarding the proximity of the proposed new maintenance access and slip road on the A12 to GEL’s existing access and egress into its site. In summary, GEL opposes the acquisition of its land interests and would like the opportunity to discuss the matter with HE to see if there is a way in which its concerns can be addressed and accommodated within the scheme proposals. We would also like the opportunity of expanding upon our grounds of objection via the Examination process and to appear at any hearings into the use of compulsory acquisition powers."
Parish Councils
Ingatestone & Fryerning Parish Council
"Ingatestone & Fryerning Parish Council welcome any efforts by Essex Highways to improve the safety and traffic flow through this busy junction. The Proposed scheme appears to be a positive step forward without closing and completely re-designing the junction all together from scratch."
Local Authorities
London Borough of Havering
"London Borough of Havering Relevant Representation for Registering as an Interested Party Relevant Representation The Council acknowledges that Junction 28 of the M25 (also known as the Brook Street interchange) (“the Junction”) is a collision ‘hotspot’ as well as a junction that currently experiences significant levels of congestion. The operation of the Junction impacts the journey times of residents of Havering. The Council recognises that traffic volumes at the Junction are expected to increase significantly over the next 15/20 years and improvements to the Junction are required either through additional capacity improvement or through other forms of demand management to manage future increases in demand. Strategic modelling work developed to support the Council’s emerging Local Plan demonstrated that traffic volumes are expected to increase on major routes going through the borough (including the Transport for London Road Network). The Council welcomes further infrastructure investment within Havering especially where this will provide for safe and convenient movement and will complement wider investment and growth in the borough. The Council does have concerns about several aspects of the Scheme. These include the following matters: Construction traffic and the knock-on effects on traffic in Havering, lighting, air quality, noise and the environment, including the implications of the Scheme and the Lower Thames Crossing scheme potentially being constructed in tandem. Whilst construction routes have been considered, it is not clear how the traffic will divert onto local roads and what the impacts will be. The Council notes that the closure of the A12 Eastbound off-slip for construction purposes is not preferred by Highways England (HE) at this stage, although lane restrictions are. The finalisation of such details is, however, left to the construction contractor by virtue of dDCO Requirement 10. Havering has significant concern that if a contractor instigated full closure of the A12 EB off-slip there would be severe limitation on accessibility for local residents in Woodstock Avenue (which has a left-in / left-out access to the A12 only). Closure of the A12 off slip would lead to an unacceptable 14km diversion to the Ingatestone A12/A1023 interchange to travel westwards to the remainder of the borough and other destinations in the greater London area. Impacts of the scheme on local traffic. The Transport Assessment (TA) for the scheme does not examine through local traffic modelling the issue of local traffic impacts. Of particular relevance is understanding the impact on Gallows Corner junction. Gallows Corner is a five-arm junction connecting the A127 and A12 trunk routes as well as two of Havering’s own roads (A118 Main Road and Straight Road). This junction currently experiences severe congestion particularly during peak periods. The Council has concerns over the A12 between the Brook Street Interchange and Gallows Corner Junction and the approaches to the A12 on borough operated roads. A number of Havering’s junctions already operate at capacity so it is important that the “knock on” implications of this Scheme on the wider road network are fully understood. It should be noted that access to the main construction compound also requires further clarification as at present this is not fully addressed in the Transport Assessment (TA). Noise. The Havering Noise Important Area (NIA) is set within the boundary of the proposed scheme. Of particular note, Gallows Corner junction is located within the NIA. Further evidence is required to understand the level of noise impacts arising from the scheme at a local level and any appropriate mitigation. Air quality. The Council has an Air Quality Management Area which is within the boundary of the proposed scheme. If additional traffic is forecast to use the boroughs strategic roads, in particular the A127 and Gallows Corner junction, the average annual mean levels for NO2 and PM10 are considered highly likely to deteriorate. Local traffic modelling of Gallows Corner and the local road network is required to evidence the air quality impact of the proposed scheme on the local road network. Heritage. Of the Designated Heritage Assets identified within Chapter 11: Cultural Heritage (11.7.2-7), the following are within the London Borough of Havering: • Tylers Hall Farm House – Grade II Listed Building – HE Ref: 1079905 • Timber Framed Range of Weatherboarded Outbuildings to Tylers Hall Farmhouse – Grade II Listed Building – HE Ref: 1183938 The Cultural Heritage Chapter does not discuss or conclude upon potential impacts to the two listed buildings at Tylers Farm. Whilst it is believed that the scheme will not have a significant adverse effect upon these two designated heritage assets this does need to be evidenced within the Environmental Statement. Of the Non-Designated Heritage Assets identified within Chapter 11: Cultural Heritage (11.7.8-9), the following are within the London Borough of Havering: • DLO33196 • DLO33198 • DLO33238 • MLO23390 • MLO12476 • MLO14553 • MLO15564 • MLO104464 • MLO104564 • MLO109095 • MLO109189. The Cultural Heritage Chapter does not decisively conclude whether there would be an impact (adverse or otherwise) upon all of these non-designated heritage assets. The nineteenth century timber framed buildings (Grid Ref: 556600, 192439) associated with Grove Farm have not been included in the assessment. This omission was noted in the previous Built Heritage consultation (dated May 2020). These buildings were considered within Preliminary Environmental Information Report (dated Nov 2018) and remain included in Appendix 11.2 (Archaeological Desk-Based Assessment). The conclusion that they are not heritage assets (Chapter 11: Cultural Heritage – 11.7.34) is not evidenced. Landscape and green belt implications. The Council is generally satisfied with the landscape and visual impact assessment findings and the concluding significance of effect(s). However, the panoramic photographs within the Landscape and visual figures document (Doc ref: TR010029/APP/6.2) have not been presented in accordance with The Visual Representation of Development Proposals Technical Guidance Note (TGN) 06/19 (Landscape Institute, September 2019). This visual representation is important as it ensures the assessment of visual impact and overall significance of effect(s) is accurate and in turn an appropriate judgement of the assessed impacts can be made. For instance, the panoramic photographs should be presented as cylindrical panoramas of up to 90° HFoV at A1 width with an image size of 820mm x 250mm. Cumulative impacts. In addition to the Scheme for the M25 J28, a further DCO scheme is being prepared by HE for a new crossing over the River Thames between Thurrock and Kent known as Lower Thames Crossing. The Council is extremely concerned about the potential cumulative impact arising from two substantial infrastructure projects being built concurrently in close proximity to the borough’s strategic highway network. It is likely that there will be a considerable adverse impact on the local highway network in the borough and its wider environment if traffic is displaced from the motorway during and post construction of these projects. There is no evidence cumulative impacts of land use proposals outside the M25 corridor have been assessed. Drafting of the Draft Development Consent Order. The wording of the draft DCO fails to meet our expectation. The Council has concerns that we ask the ExA to consider. We see no requirement to remove temporary works. The approval processes for requirements and documents exclude LB Havering in a number of areas of environmental responsibility which fall to itself. The principle of “deemed consent” for matters which fall to Havering to determine is unacceptable as is the concept of ‘consultation’ which, as currently set out, invites consultation to take place but not a requirement to reach substantive agreement with Havering on matters within it compass. Havering will require authority to inspect the works with regard to environmental matters within its remit. The Council retains the right to comment on other areas of the applicant’s proposals as the Examination proceeds."
Members of the Public/Businesses
The Jones Family
"We [Redacted] have a number of businesses in operation here providing employment for maybe 100 people. Our property will be significantly affected by the proposals. We have grave concerns about the proposed works on both our living conditions and the ongoing operation of our business and the others that are located here. The views we have expressed to the project team over the last 2 years about the proposed design do not appear to have been incorporated in to the submission. We note that the proposed new A12 east bound slip road would be located some 20m nearer to our property and at a significantly greater elevation making it level with our bedroom window. We have not seen any details of noise and vibration mitigation measures and we are therefore unable to understand the impact on our living conditions. The submitted information understandably deals with these issues generally but we believe that there is insufficient evidence provide to support the assertion that the impact would be negligible is hard for us to understand. The proposals show a new exit from the site at approximately the same location as the existing exit but with an approach some 20m shorter, reducing the space for vehicles to wait when exiting the site. We believe that it would be feasible and preferable to move the exit westwards down the slip road and away from our house to provide more room for exiting vehicles to queue and where they would be a better distance form our house. The proposals show the existing entrance to the site being maintained in its current position and a new exit slip from the M25 north entry slip road being built to provide maintenance access. We believe that it is feasible and preferable for these to be combined into one access serving both the site and the maintenance requirements. We would ask that the balancing/attenuation pond shown to be constructed be relocated as far north as possible to keep it clear of our other activities on site. We have asked for further information and engagement from the applicant on these issues but regrettably none of the issues we have raised have been resolved."
Members of the Public/Businesses
response has attachments
Transport for London
"TfL is the integrated transport authority for London with responsibilities including the maintenance, management and operations of London’s main roads, known as the Transport for London Road Network (TLRN). The A12 at M25 Junction 28 and towards London to the west is part of the TLRN and is directly affected by the proposed scheme. We are supportive of the scheme in principle but our representation outlines where we have identified issues in our review of the application documents, including where we need to register our objection or reserve our position until more information is provided. We are continuing to engage with the applicant on these matters. A document containing our detailed Representation has been sent to the [email protected] email address."
Members of the Public/Businesses
Wasif Ahmed
"The project impacts my property which is on A12. [Redacted] The project will increase: Noise pollution Air pollution Increase the chance of lung related diseases Reduce the value of my property as a result of above I have highlighted the points before but have not received any response to the above. The above points will form part of my principal submissions in relation to the to the project."
Local Authorities
London Borough of Havering
"Thank you for the opportunity to comment on proposed Change 2 submitted by the Applicant at Deadline 3a. London Borough of Havering commented on the proposal for Change 2 in the Targeted Consultation that the Applicant held earlier this year. Havering’s consultation comments have been summarised in Appendix A of REP3A-030 submitted by the Applicant at Deadline 3a. LB Havering welcomes the proposal for a permanent environmental bund which will result in a slight reduction in visual impact compared to the existing scheme. It is noted in the Applicant’s response to LB Havering’s comments on Change 2 (Table 3.1 Appendix A REP3A-030), that the management of this bund will be covered in the Outline Landscape Ecological Management Plan (LEMP). However, in its response to the Targeted Consultation, LB Havering encouraged the Applicant to include this measure within the recommendations that are set out within Table 6.1 of the outline LEMP (APP-072). On review of Appendix E in REP3A-030 which sets out the Applicant’s proposed changes to the outline LEMP, this change does not appear to have made. LB Havering would reiterate its comments made during Targeted Consultation, and is of the view that the environmental bund should be included in Table 6.1. LB Havering is encouraged that following comments at Targeted Consultation, the Applicant will take into consideration the recommendations Havering has previously provided Highways England with regards to planting selection and implementation. Havering looks forward to seeing how these recommendations have been taken into account in the updated outline LEMP."